3 December 2014

 FBME Bank submitted to FinCEN on 1 December 2014 a comprehensive forensic accounting report made by experts from the international consulting firm E&Y (Ernst & Young). In addition, the Bank has submitted to FinCEN hundreds of pages of documents regarding its anti-money laundering compliance programme and know-your-customer procedures. Submission to FinCEN was made on FBME Bank’s behalf by the international law firm Hogan Lovells.

On Friday, 18 July 2014, the FinCEN bureau of the US Department of Treasury issued a Notice naming FBME Bank as a ‘foreign banking institution of primary money laundering concern’, and later issued a Notice of Proposed Rulemaking. The FinCEN Notice of Proposed Rulemaking has not been finalized by the US authorities, and FBME Bank is working in cooperation with FinCEN to address its concerns so that the Notices can be withdrawn.

At the time of the first submission to FinCEN, Hogan Lovells issued a Public Comment on the findings of the forensic accountants and other investigations, a copy of which can be found here.